Revised Timelines for CMS Claims Reporting

The Centers for Medicare & Medicaid Services (CMS) has just issued revised timelines for Mandatory Insurer Reporting. The CMS announced the new implementation timelines for reporting claims under the Medicare, Medicaid, and SCHIP Extension Act (Section 111) in a November 9, 2010 memo.

Mandatory settlement reporting for liability TPOCs has moved from the first quarter of 2011 to the first quarter of 2012. The TPOC, or “Total Payment Obligation to Claimant,” refers to the dollar amount of a settlement, judgment, award or other payment in addition to/apart from ORM.

In workers’ comp and no-fault cases involving ORM, or “Ongoing Responsibility for Medical” (when medical expenses are paid during the handling of the claim without or prior to a settlement or judgment) the beginning mandatory reporting does not change. It is still first quarter 2011.

In addition, while interim dollar reporting threshold amounts do not change, reporting dates have been pushed back by one calendar year.

For ORM reporting, the clock is ticking. The delay in TPOC reporting should not be seen as an opportunity to do nothing for a year. Use the time to ensure your clients’ documentation is correct and ready to go.

If you have any questions on this matter, please give me call. Jon Gunter, Executive Vice-President at MEDVAL, is also available at 949-203-3021, jgunter@medval.com.

Patrick C. Farber

Pat Farber has 35 years of insurance experience with more than 30 years in the structured settlement field. Pat specializes in providing structured annuities for medical malpractice, personal injury, product liability, workers’ compensation, toxic torts, and construction defect cases as well as for non-physical injury cases and attorney fees. He participates in court hearings, arbitrations and settlement conferences throughout California, the West Coast and in other areas of the United States. He has personally placed over $3 billion in annuity premiums and U.S. Government notes.

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